Int'l Tax News

Posted on

Economic Analysis: Trending Ideas That Could Shape Future Tax Policy

by Martin A. Sullivan
In this fluid environment, tax ideas that until just recently have been trapped by gridlock could rise to the surface.
For the Tax Notes article, gohere. (subscription required)

Posted on

U.S. Official: Unilateral Measures Violate Spirit of BEPS

by Kevin A. Bell
U.S. policy makers are dismayed that members of the OECD's project to combat tax base erosion and profit shifting have already enacted unilateral measuresÔøΩand that more are in theworks, a Treasury official said.
For the DTR story, go here. (subscription required)

Posted on

Tough Cash Pool Decisions Ahead Under Debt-Equity Rules

by Alison Bennett
Multinationalswith common cash management structures known as "cash pools" are bracing for a bumpy ride under controversial earnings-stripping rules.
For the DTR story, go here. (subscription required)

Posted on

India and Mauritius treaty protocol introduces source-based taxation of shares

  • By PwC

The governments of India and Mauritius signed a protocol amending the countries' tax treaty on May 10, 2016.

Key features of the protocol include the introduction of source-based taxation of capital gains on the transfer of Indian companies' shares acquired on or after April 1, 2017, and source-based taxation of interest income of Mauritian banks and fees for technical services.

For the PwC Insight, gohere.

Posted on

U.S. Groups Argue Against Earnings-Stripping Rules

by Richard Rubin
U.S. business groupsasked the Treasury DepartmentThursdayfor more time to analyze rules that tighten restrictions on intercompany debt and make it harder for companies to push taxable profits out of the U.S.
For thewall Street Journal story, go here.

Posted on

Heads of tax administrations take big step forward in global tax co-operation

  • By OECD
by OECD
Delivering on the OECD/G20 international tax agenda, through implementation of the Base Erosion and Profit Shifting (BEPS) Project and the Common Reporting Standard (CRS) for the automatic exchange of financial account information, took centre stagewhen heads of tax administrations met on 11-13 May in Beijing, People's Republic of China.
For the OECD release, go here.

Posted on

European Parliament Approves Country-by-Country Reporting

by Joe Kirwin
The European Parliament cleared theway for legislation to require multinational companieswith a turnover of 750 million euros ($847 million) or more to provide country-by-country tax and profit information to European Union member state tax authorities.
For the DTR story, gohere. (subscription required)

Posted on

Quit Bullying, Fight Corruption in U.S., Tax Havens Say

by Thomas Penny & Stephanie Baker
The global fight against corruption should focus on major jurisdictions rather than bullying small territories, the heads of government of two tax havens toldworld leaders.
For the DTR story, go here. (subscription required)

Posted on

Officials Defend Distribution Rule in Anti-Inversion Regs

by Andrew Velarde
IRS and Treasury officials on May 12 defended the bright-line non-ordinary-course-distribution (NOCD) rule of the recent anti-inversion regs, saying itwas necessary to prevent companies from billing themselves as attractive inversion targets.
For the TNT story, gohere. (subscription required)

Posted on

Coalition Renews Push to Cut U.S. Funding for OECD

by Alex M. Parker
A coalition of free-market advocacy groups is renewing its campaign for the U.S. to sever funding to the OECD in thewake of the organization's project to combat tax base erosion and profit shifting.
For the DTR story, go here. (subscription required)

Posted on

IRS Advises Agents on Taxpayer Use of Section 482

by Dolores Gregory
If a U.S. taxpayer adjusts the book price of a transactionwith a foreign parent to reflect an arm's-length price, it must report the corrected amount on a timely filed original Form 1120, the IRS said in a new international practice unit.
For the DTR story, go here. (subscription required)

Posted on

Give Us More Time on Debt-Equity Rules, Groups Ask Treasury

by Alison Bennett
Nearly two-dozen business and industry groups are asking the government to back down on the effective date for controversial earnings-stripping rules and offer months of additional time for commentsÔøΩa sign of the growing pressure on the Treasury Department to ease up on the regulations.
For the DTR story, go here. (subscription required)

Posted on

Tax Treaty Break From Inversions Rules Possible: Treasury

by Alison Bennett
Multinationals could get a break under controversial inversions rules if they don't get a better tax deal under the treaty in a new "third country" than they did in the jurisdiction they left, a Treasury Department official said.
For the DTR story, gohere. (subscription required)

Posted on

Debt-Equity Bifurcation Could Expand Beyond Related Parties

by Laura Davison
The Treasury Department could decide towrite rules allowing the government to break up debt contracts into debt and equity pieces for transactions that don't involve related parties, an official said.
For the DTR story, go here. (subscription required)

Posted on

European Green Party: U.S. Should Be On Tax Haven List

by Joe Kirwin
The U.S. should be listed as a tax haven if it doesn't take steps to expose beneficial owners of companies and if the OECD's common reporting standard isn't adopted, the European Green Party said.
For the DTR story, go here. (subscription required)

Posted on

Report Calls U.S. Multinationals' Tax Disadvantage Exaggerated

by Ryan Finley
The United States' comparatively high corporate tax rate and taxation ofworldwide income haven't made U.S. multinationals uncompetitive, and lowering the rate or adopting a territorial systemwon't fixwhat'swrongwith the current system, according to a reportwritten by economist Kimberly A. Clausing.
For the TNT story, go here. (subscription required)

Posted on

A new boost to transparency in international tax matters: 6 new countries sign agreement enabling automatic sharing of country-by-country reporting

  • By OECD
by OECD
As part of continuing efforts to boost transparency by multinational enterprises (MNEs), Canada, Iceland, India, Israel, New Zealand and the People's Republic of China signed today the Multilateral Competent Authority agreement for the automatic exchange of Country-by-Country reports ("CbC MCAA"), bringing the total number of signatories to 39 countries. The signing ceremony took place in Beijing, China.
For the OECD release, go here.

Posted on

The Necessary and Valuable Economic Role of Tax Havens

Simply stated,when politicians have toworry that jobs and investment can cross borders, they are less likely to impose higher tax rates and punitive levels of double taxation. Interestingly, even the statist bureaucrats at the Organization for Economic Cooperation and Development agreewith me,writing that tax havens "may hamper the application of progressive tax rates." They think that's a bad thing, of course, butwe both agree that tax competition means lower rates.

So Iwas very surprised to see some economists signed a letter saying that so-called tax havens "serve no useful economic purpose."

For the Cato article, gohere.

Posted on

If Everyone Is a Tax Haven, No One Is

by Alan Cole
The European Green Party today labeled the United States a tax haven, particularly singling out the states of Arkansas, Colorado, Delaware, Indiana, Iowa, Maryland, Michigan, Mississippi, Missouri, New York, Ohio, Oklahoma, Pennsylvania, and Virginia. That's a lot of states, places that most just consider ordinary areas inwhich to do business.
For the Cato article, gohere.

Posted on

PE changes increase risk of tax exposure in jurisdictions where a company has no legal entity

  • By International Tax Review

Multinational enterprises (MNEs) are facing new challenges arising from OECD's developments regarding the determination of a taxable presence in a foreign countrywhere the company operateswithout a legal entity.


For the ITR article, go here.

Posted on

Section 385 proposed regulations would vitiate internal cash management operations

  • By PwC

by PwC

On April 4, 2016, Treasury and the IRS proposed regulations under section 385. The Proposed Regulations appear to be intended to limit the effectiveness of certain tax planning techniques by recharacterizing certain related-party financings as equity, evenwhere the financing is in the form of straight debt instruments.

For the PwC Insight, gohere.

Posted on

U.S. Competent Authority statistics for 2015 reflect the global controversy environment and the growing need for relief from double taxation

  • By PwC

by PwC

The U.S. Competent Authority (USCA) office, on April 27, 2016, released statistics on cases addressed under the mutual agreement procedures (MAP) for calendar year 2015 (Report), including the number of MAP cases submitted, the number of cases closed, completion time, and pending cases.

The statistics show that APMA and U.S. treaty partners continue to provide taxpayerswith relief from double taxation in almost all allocation cases.
For the PwC Insight, gohere.

Posted on

Profit shifting and U.S. corporate tax policy reform

byKimberly A. Clausing
Corporate tax reform should focus on base erosion over competitiveness and could include small reform provisions such as stronger earnings stripping rules and an exit tax to reduce inversions alongwith broader return consolidation and apportionment measures, Kimberly A. Clausing of thewashington Center for Equitable Growth said in a May report.
For the report, go here.

Posted on

U.S. companies are saving $100 billion a year by shifting profits overseas, report says

by Renae Merle
U.S. multinational companies are saving $100 billion a year by shifting profits overseas to lower theirtaxbills, according to a study releasedTuesdaythat concluded that corporatetax-dodging is a bigger problem than previously estimated.
For thewashington Post story, gohere.

Posted on

The New U.S. Model Treaty Is Out!

by James J. Tobin
Iwas excited by the release of the new U.S. Model Treaty (the Model). It brings to mind one of my favorite scenes from the old movie "The Jerk"where Steve Martin is running down the street exclaiming "the new phone books are out, the new phone books are out." Unfortunately, after reading the Model and recognizing the difficulty the United States has in ratifying treaties or protocols in the first place, I'm not convinced the new Modelwill have much more effect than the new phone books Steve Martinwas so excited about.
For the Premier International Tax Library article, gohere.

Posted on

Is Tax Playing A Role In Weak Corporate Earnings?

First-quarter corporate earnings season is drawing to a close on a sour note. Quarterly profits are down 7.1% from a year ago, according to the Thomson Reuters TRI +% consensus estimate. There are a lot of reasons for this: a shaky global economy, persistently slow GDP growth in the U.S. and China, and the free-fall in crude oil prices, to name a few.

But there's also a new culprit that's emerging as a particularly challenging earnings headwind for multinational corporations: tax.

For the Forbes article, gohere.

Posted on

BEPS Brings on Information Overload, IRS Official

by Doloresw. Gregory
Increased government access to taxpayer data creates more opportunity to track down tax cheats, but the speed of the information flow threatens to swamp tax authoritieswith more data than they can process, an IRS official said.
For the DTR story, gohere. (subscription required)

Posted on

Expanded Group Definition in Debt/Equity Regs May Be Narrowed

by Amy S. Elliott & Lee A. Sheppard
The expanded group definition in the contentious proposed section 385 regulations may be narrowed, government officials hinted at the May 7 Corporate Tax Committee session of the American Bar Association Section of Taxation meeting inwashington.
For the TNT story, gohere. (subscription required)

Posted on

Pain of Earnings-Stripping Rules Might Ease: Treasury

by Alison Bennett
The bite of controversial earnings-stripping rules may be less painfulwhen the guidance is finalized, Treasury officials indicated at the May meeting of the American Bar Association Section of Taxation.
For the DTR story, gohere. (subscription required)

Posted on

American Business Competitiveness Act: Good Steps Toward Business Tax Reform

by Curtis S. Dubay & David R. Burton
The U.S. has the highest corporate tax rate in the developedworld. Houseways and
Means Committee Member Representative Devin Nunes (R–CA) has introduced new legislation for business tax reform, called the American Business Competitiveness Act (H.R. 4377). Two Heritage Foundation tax policy analysts explain how the legislationworksÔøΩand how it could be changed towork even better.
For the Heritage report, gohere.

Posted on

Obama's Wall Is Bad Too

by Alex Brill
The Obamawall is very real. It has stopped pending business transactions dead in their tracks, created costs and uncertainties at every Fortune 500 company in America, and moved the tax policy debate in thewrong direction.
For the US News article, go here.

Posted on

Tax Writers Continue Examining Tax Reform Proposals as Administration and Regulators Focus on International Issues - See more at: http://www.natlawreview.com/article/tax-writers-continue examining tax

by Brandon C. Roman & Stephanie L. Shaker
While it is presently unclear the extent towhich details from Representative Boustany's international tax reform proposalwill be included in the "blueprint," it is clear that he has put forth significant effort to prepare his measure and likely has his detailed proposal at the ready, should that level of detail ultimately be appropriate to include in the broader tax reform proposal.
For the National Review article, go here.

Posted on

PE changes increase risk of tax exposure in jurisdictions where a company has no legal entity (1)

  • By ITR

Multinational enterprises (MNEs) are facing new challenges arising from OECD's developments regarding the determination of a taxable presence in a foreign countrywhere the company operateswithout a legal entity.


For the ITR story, go here.

Posted on

No More Hiding in U.S. Disregarded Entities Under IRS Rules

by Alison Bennett & Chris Marr
The Treasury Departmentwants towrite an exception in final earnings-stripping regulations for cash-pooling arrangements that involve routine, daily "sweeps" of cash,while cracking down on long-term financing arrangements that look like problematic loans, Treasury International Tax Counsel Danielle Rolfes said.
For the DTR story, go here. (subscription required)

Posted on

Patent Box Meeting OECD Rules Likely OK for U.S Model Treaty

by Alex M. Parker
A patent or innovation box that passes new OECD standardswill also likely be acceptable under the new U.S. model tax treaty, according to a Department of Treasury official.
For the DTR story, gohere. (subscription required)

Posted on

Final Country-by-Country Rules May Address Territories

by Alex M. Parker
Final U.S. regulations implementing the OECD's country-by-country reporting scheme likelywill address how to consider quasi-independent territories such as Puerto Rico, a Treasury Department official said.
For the DTR story, go here. (subscription required)

Posted on

Debt-Equity Regs May Change Current Law

bywilliam R. Davis & Lee A. Sheppard
Government officialswho participated in the drafting of the proposed regulations undersection 385were challenged May 6 by practitioners on the degree towhich the new rules might change current law.
For the TNT story, go here. (subscription required)

Posted on

U.S. Model Treaty Emphasizes Antiavoidance Measures

by Alexander Lewis
The IRS has become aware of U.S. tax treaties' role in international tax avoidance schemes, and the most recent U.S. model treaty includes several changes designed to curb that abuse, according to Danielle Rolfes, Treasury international tax counsel.
For the TNT story, go here. (subscription required)

Posted on

News Analysis: A New Protectionism in U.S. Tax Policy?

by Mindy Herzfeld
Mindy Herzfeld examines the recent push in the U.S. to increase the tax burden on foreign multinationals, and explainswhy those multinationals and other advocates for increased foreign direct investment in the U.S.will not go downwithout a fight.
For the TNI article, go here. (subscription required)

Posted on

U.S. Tax Review (1) (4)

by James P. Fuller
In this article, James P. Fuller discusses section 385 and 7874 regulations, advance pricing agreements, and theCheri LaRuecase.
For the TNI article, go here. (subscription required)

Posted on

How foreign tax changes affect U.S. businesses and the prospects for tax reform

  • By Brookings Institution

by Brookings Institution

Changes in the taxation of business income by our major trading partners are creating shockwaves in the United States. On Tuesday, May 3, the Urban-Brookings Tax Policy Center examined the implications of theseworldwide changes for tax reform in the U.S. The symposium is named for Donald C. Lubick,who served in senior tax policy positions in the government for over four decades, and honors his extraordinary record of public service on behalf of better tax policy.

For the video of the conference, gohere.

Posted on

Profit Shifting Under Pressure

  • By Credit Suisse

Multinationals are facing a tougher tax environment, and it's coming atthem from a number of different angles.

For the Credit Suisse release, go here.

Posted on

States May Follow Treasury's Lead on Debt-Equity Rules

by Alex M. Parker
Now that the Treasury Department has issued new regulations strengthening rules on the classification of intercompany debt and equity, states may soon follow, a Multistate Tax Commission official said.
For the DTR story, gohere. (subscription required)

Posted on

Related-Party Debt Rules Could Clarify Partnership Lending

by Laura Davison
Government officials are debatingwhether debt issued by a partnership to a consolidated groupwould be subject to the substantiation requirements in proposed rules on related-party debt, an IRS representative said.
For the DTR story, go here. (subscription required)

Posted on

300 economists urge leaders to reject tax havens

by Danika Kirka
Hundreds of economists urgedworld leaders Monday to end the era of tax havens, arguing they only benefit rich individuals and multinational corporations and serve to increase inequality.
For the Seattle Times story, go here.

Posted on

Economic Analysis: For Economy's Sake, Time for Tax Reform Compromise

If Republicans reallywant business tax reform, they need to get out of their bubble and face the political reality. In the short term, they should consider drafting small-scale tax reform legislation that Clinton can sign. But it isn't just Republicanswho need a new mind-set. If Democrats reallywant to help Americanworkers, they need to get out of their own bubble and face the economic reality.

For the Tax Notes article, gohere. (subscription required)

Posted on

U.S. Taking Cautious Approach to Adoption of New PE Standard

by Ryan Finley
Before agreeing to incorporate the OECD's revised definition of permanent establishment into bilateral tax treaties, Treasury officialswant to be confident that countrieswill attribute profit to a PE in a consistent manner, according to Brian Jenn, attorney-adviser, Treasury Office of International Tax Counsel.
For the TNT story, go here. (subscription required)

Posted on

IRS Related-Party Debt Rules to Increase States' Focus on Transfer Pricing

by Amy Hamilton
The IRS's newly proposed related-party debt reclassification ruleswill likely pique -- rather than diminish -- state tax authorities' interest in transfer pricing reviews, practitioners said May 6.
For the STT story, go here. (subscription required)

Posted on

No 'Legitimate Expectations' in Excess Profit State Aid Case, Commission Says

For thewWTD story, go here. (subscription required)

Posted on

U.S. Inversion Rules Expected to Affect Canadian Companies

by Peter Menyasz
New U.S. regulations designed to prevent companies from shifting profits offshore, particularly through inversion transactions, may unintentionally capture Canadian companies, an international tax practitioner said.
For the DTR story, gohere. (subscription required)

Member Companies

Back to top